Posts Tagged: Safety

What are the changes is OSHA’s recordkeeping requirements for the manufacturing industry?

OSHA has adopted a new electronic data submission rule that took effect January 1, 2017. The new rule requires certain categories of employers (see applicability thresholds below) to electronically submit injury and illness data that they are already required to record on their on-site OSHA injury and illness forms. While the rule took effect on January 1, 2017, according to OSHA, the website employers must use went live in February 2017. Some of the data submitted will ultimately be posted to the OSHA website. The amount of data submitted will vary depending on the size of the company and the type of industry.

OSHA will provide a secure website that offers three options for data submission:

Users will be able to manually enter data into a web form.

Users will be able to upload a CSV file in order to process single or multiple establishments at the same time.

Users of automated record-keeping systems will have the ability to transmit data electronically via an application programming interface (API).

Effective July 1, 2017: Establishments with 250 or more employees in industries covered by the record-keeping regulation must submit information from their 2016 Form 300A and 2017 data on July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

Effective July 1, 2017: Establishments with 20–249 employees in certain high-risk industries (OSHA defines these as industries with historically high rates of occupational injuries and illnesses) must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

The list of Industries covered by this rule can be found on OSHA website. If you believe you would be exempt under the small employer rule, you should verify by visiting OSHA’s website and looking for your NAICS code on the list. The list of high-risk industries is available at the OSHA website. Finally, new industries have been added to the record keeping rule. Check to see if you are on the newly required list.

As a reminder, make sure that your OSHA 300A log is posted in an area where all of your employees can access it. Even if you had zero recordables on your OSHA 300 A log, you still must post with zeros. This document must be posted from February 1, 2019- April 30, 2019. This document must be signed by a company executive. 29 CFR 1904.32(b)(3) states How do I certify the annual summary? A company executive must certify that he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete.

Based on the Bureau of Labor Statistics report fatal work injuries involving violence and other injuries by persons or animals increased by 163 cases to 866 in 2016. Workplace homicides increased by 83 cases to 500 in 2016, and workplace suicides increased from 62 to 291. This is the highest homicide figure and the most suicides since 2010.

• The top three causes of fatalities in the workplace in order are car accidents, workplace violence and falls. To see the specific numbers for manufacturing visit the Bureau of Labor Statistics website.
With the rise of homicide in the workplace, employers need to start to address the risks associated with workplace violence. Workplace violence falls under the General Duty Clause of the Occupational Safety and Health Act, Section 5(a)(1).

Section 5(a)(1) of the Occupational Safety and Health Act, requires that each employer furnish to each of its employees a workplace that is free from recognized hazards that are causing or likely to cause death or serious physical harm.

What you need to know?

• 98% of all active shooter incidents are committed by a single person
• 78% of all active shooters know at least one of their targets
• 40% commit suicide and 48% are killed by police or others
• 88% of active shooters DO NOT expect to survive
• Most active shooter events are less than 5-7 minutes (actual shooting)

Even with a response time of 2-3 minutes by police, most of the shooting is over by the time they arrive. We need to implement training that teaches our employees response options, find ways to secure and slow down shooters within our buildings and learn advanced first aid that includes tourniquet training.
When the police arrive on scene, they are not there to treat the wounded, they are there to neutralize the threat, learning lifesaving skills like “Stop the Bleed” which includes tourniquet training, will save lives.

If you are looking for guidelines to help you get started with a workplace violence plan, consider NFPA 3000. In response to the rise of active shooter incidents, the National Fire Protection Association (NFPA) has put a provisional standard in place, NFPA 3000. Shortly after the mass killings in the Pulse Nightclub incident, the NFPA 3000 began in October 2016 and was quickly formed with a technical committee that included Department of Homeland Security; Department of Justice; the FBI; NSA: national police, fire and EMS organizations; hospitals; private security; and universities.

We can no longer say “It won’t happen here.” We need to write a program and train our staff in ways to protect against workplace violence.

OSHA, DOT, NFPA, ISO, FDA, NIOSH, ANSI, and EPA just to name a few. Who regulates you? Who has the authority? Where do you begin? And, why do all the agencies have a different interpretation of the regulations?

OSHA is the Occupational Safety and Health Administration and you can find their standards for general industry online at OSHA.gov or in the 29 CFR 1910 General Industry Standards Book. Their mission is to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.

The sheer size and weight of the 29 CFR 1910 OSHA General Industries Standard Book of regulations can be overwhelming. So, let us recommend a better way for you to get started building your safety program. Take a look at the OSHA’s Small Business Handbook. This handbook will get you started on what regulations apply to almost every industry and provide the template for a health and safety management system.

Being responsible for your company’s health and safety management system, policies, procedures, programs, testing, equipment and training, is a full-time job. We can help save you time.

Requirements for welding, cutting and hot work permits have changed for manufacturing.

As a result of the tragic fire on March 26, 2014, where two Boston firefighters were killed from a fire that started by unpermitted and improper welding activity, all employees performing hot work must be trained by a Massachusetts state approved training program.

You need to review the definitions and terminology around this new requirement and make sure your current hot work permitting process is also up to code. Your local fire departments willnow be responsible for issuing permits to do hot work on a daily basis. There are some exemptions, but you need to prove exemptions and work with your local fire departments.

Let’s start with the simple definition of hot work.

Hot work is any work process that involves heat, spark, or flame that is capable of starting fires or explosions. Examples include, but are not limited to, welding, cutting, grinding, soldering,heat treating, hot riveting, torch applied roofing, abrasive blasting, and powder driven fasteners.

Does your current hot work internal permitting process include any of the following;

Working in a designed area that has been pre-approved by the fire or building officials.

A minimum of a 30-minute fire watch after completion

An annual permit from the fire department

A permit authorized individual (PAI) who is also “qualified”

Does your hot work permit include work location, type of hot work, the work to be done, the operator, duration, equipment, and controls to ensure safety?

A clear definition of permitted vs. designated area

You should be reviewing your current hot work permitting process today. Make sure that you are up to date with the new hot work permitting requirements. Even if you said yes to all of theabove, you are still out of compliance, if your employees do not have a certificate from one of the two approved training programs. This training program, currently, cannot be done in-house.

Who must complete a training program?

A qualified person must provide documentation that he or she has successfully completed an approved training program in order to serve in any of these capacities:

Anyone who performs hot work.

Anyone who serves as a “Permit Authorizing Individual” (PAI) to perform, supervise or delegate hot work;

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